ML18152A472

Responds to NRC 971224 Ltr Re Violations Noted in Insp Repts 50-280/97-09 & 50-281/97-09.Corrective Actions:Appendix R Awareness Training Will Be Conducted for Appropriate Personnel in Nuclear Business Unit

ML18152A472
Person / Time
Site:	Surry
Issue date:	01/20/1998
From:	OHANLON J P VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-280-97-09, 50-280-97-9, 50-281-97-09, 50-281-97-9, 97-745, NUDOCS 9801270034
Download: ML18152A472 (13)

See also: IR 05000280/1997009

Text

• * VIRGINIA ELECTRIC AND PowER CoMPANY RICHMOND, VIRGINIA 23261 January 20, 1998 United States Nuclear Regulatory

Commission

Attention:

Document Control Desk Washington, D. C. 20555 Gentlemen:

VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 REPLY TO A NOTICE OF VIOLATION

Serial No. SPS/CGL Docket Nos. License Nos. NRC INSPECTION

REPORT NOS. 50-280/97-09

AND 50-281/97-09 97-745 R2" 50-280 50-281 DPR-32 DPR-37 We have reviewed Inspection

Report Nos. 50-280/97-09

and 50-281 /97-09 dated December 24, 1997, and the enclosed Notice of Violation (NOV) and Notice of Deviation

for Surry Units 1 and 2. In response to the issues raised in the inspection

report, we have taken corrective

actions and plan additional

actions. The actions focus on restoring

vital bus isolation

and providing

breaker coordination, heightening

personnel

awareness

relative to Appendix R, ensuring that a situation

similar to the vital bus isolation

issue does not exist, and continuing

our programmatic

review of the Appendix R program. The commitments

made in this letter are summarized

below. We have no objection

to this letter being made part of the public record. Please contact us if you have any questions

or require additional

information.

Very truly yours, James P. O'Hanlon Senior Vice President

-Nuclear Attachment

9801270034

980120 PDR ADOCK 05000280 G PDR * '-' .J ... , I llll/111/111111111111

lflll//l/111111111

• .i !:ii C 7 * o/

1---* * * cc: US Nuclear Regulatory

Commission

Region II Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, Georgia 30303 Mr. R. A. Musser NRC Senior Resident Inspector

Surry Power Station SUMMARY OF COMMITMENTS

The following

commitments

are made in response to the Notice of Violation

and Notice of Deviation

in NRC Inspection

Report Nos. 50-280/97-09

and 50-281/97-09:

1 . The modifications

to address the vital bus isolation

and breaker coordination

issues will be completed

on Unit 1 during the next refueling

outage. The required compensatory

measures will remain in place until the modifications

are completed

on Unit 1. [October -November 1998 refueling

outage] 2. Appendix R awareness

training will be conducted

for appropriate

personnel

in the Nuclear Business Unit. This training will focus on the Appendix R design and licensing

bases, as well as Appendix R compliance

and implications.

The awareness

training will include a discussion

of how insufficient

communication

contributed

to the inappropriate

prioritization

and delay in implementation

of the modification.

[First Quarter 1998] 3. A memorandum

will be issued to appropriate

Nuclear Business Unit personnel

describing

how the use of ambiguous

language contributed

to the delay in implementation

of the required modifications

and reinforcing

the need for and management

expectation

of effective

communication.

[February

1998] 4. A multi-utility

assessment

of our Appendix R Program will be conducted

using the applicable

portions of the draft Fire Protection

Functional

Inspection (FPFI) Temporary

Instruction

2515/xxx, which was used during the recent River Bend FPFI. [April 1998 -Reference:

Letter S/N 98-020] 5. A multi-disciplined

review of portions of the Appendix R Report will be conducted.

This review which will include Chapters 3 and 4 will assess the accuracy of the Appendix R Report relative to the current plant configuration, and will validate compliance

with the Appendix R requirements.

[July 15, 1998] 6. The fire protection

administrative

procedure

will be expanded to include the original bases for the existing compensatory

measures.

Consistent

with the guidance in Information

Notice 97-48, the fire-watch-only

compensatory

measures will be reviewed for possible expansion

to include other interim measures, such as operator briefings, temporary

repairs or procedures, installation

and use of temporary

fire barriers, and additional

detection

and suppression, as appropriate.

[July 1, 1998]

• REPLY TO A NOTICE OF VIOLATION . NRC INSPECTION

CONDUCTED

AUGUST 24, 1997 THROUGH OCTOBER 4, 1997 SURRY POWER STATION UNITS 1 AND 2 INSPECTION

REPORT NOS. 50-280/97-09

AND 50-281/97-09

NRC COMMENT: "During an NRC inspection

conducted

on August 24 through October 4, 1997, violations

of NRC requirements

were identified.

In accordance

with the "General Statement

of Policy and Procedures

for NRC Enforcement

Actions," NUREG-1600, the violations

are listed below: A. 10 CFR 50.48 states, in part, that each operating

nuclear plant licensed to operate prior to January 1, 1979, shall satisfy the requirements

of 10 CFR 50, Appendix R, Section 111.G. Both Surry units were licensed prior to January 1, 1979. 10 CFR 50, Appendix R, Section 111.G.1.(a)

requires fire protection

features to be provided for structures, systems and components

important

to safe shutdown to limit fire damage such that one train of systems necessary

to achieve and maintain hot shutdown conditions

from either the control room or emergency

control station(s)

is free from fire damage. 1 O CFR 50, Appendix R, Section 111.G.2 requires the protection

of one redundant

shutdown train from fire damage which could result in hot shorts, open circuits or shorts to ground during an Appendix R type fire. Contrary to the above, from July 1988 for Unit 1 and September

1989 for Unit 2 until August 29, 1997, the licensee failed to provide adequate fire protection

features for structures, systems and components

important

to safe shutdown in that adequate means were not available

to isolate the circuits from 120 volt alternating

current power panels VB 1-1 and VB 1-11 I and panels VB 2-1 and VB 2-111, located in the respective

Unit 1 and 2 computer rooms in the control room complex, from the uninterruptable

power supply (UPS) panels. Electrical

faults from a 10 CFR Part 50, Appendix R, fire in the control room complex could cause the loss of power from UPS panels 1A-1, 1A-2, 2A-1 and 2A-1 [should be 2A-2]. These UPS panels provide power to the Appendix R remote shutdown panels, located in each unit's emergency

switchgear

room and in the cable spreading

room; and, supply power to the Appendix R communication

equipment

located adjacent to the auxiliary

shutdown panels in each emergency

switchgear

room. The Appendix R panels contained

the instrumentation

required for performing

a plant shutdown from outside the main control room and included instrumentation

for steam generator

level, reactor coolant system pressure and temperature, and pressurizer

level. (01013) Page 1

• * B. Surry Operating

License Section 2.1 for Units 1 and 2 provides that the licensee is required to implement

and maintain the administrative

controls identified

in Section 6. of the Fire Protection

Safety Evaluation . The Surry Fire Protection

Program is described

in the Surry Appendix R Report. Chapter 12, Section C of the Surry Appendix R Report describes

the Quality Assurance

program that is applicable

to the fire protection

program. Section C.8 states that measures established

to ensure* that conditions

adverse to fire protection, such as failures, malfunctions, deficiencies, deviations, defective

components, uncontrolled

combustible

materials

and noncomformances, are promptly identified, reported and corrected.

Contrary to the above, as of August 29, 1997, the licensee failed to identify fully and correct a noncompliance

with Appendix R requirements

for the control room associated

with a vital bus isolation

issue discovered

by the licensee in 1992. Specifically, because the licensee failed to recognize

the significance

of the issue and the fact that the plant was outside the design basis, adequate corrective

actions and compensatory

measures were not implemented

until 1997. (01023) These violations

constitute

a Severity Level Ill problem (Supplement

I). C. 1 O CFR 50. 72(b)(1 )(ii)(B) requires the licensee to notify the NRC of identified

plant conditions

that are outside the design basis of the plant. The notification

is to be made as soon as practical

but within one hour of the occurrence.

Contrary to the above, on September

30, 1997, the licensee failed to notify the NRC within one hour of the occurrence, of conditions

outside the design basis of the plant. Specifically, on this date, the licensee determined

that Surry Units 1 and 2 had been outside its Appendix R design basis due to a 120 VAC vital bus isolation

issue. Although the licensee concluded

that the outside of design basis condition

was a past condition, the Units were in fact still outside the design basis and a one-hour report was required.

(02014) This is a Severity Level IV violation (Supplement

I)." Page 2

• * * REPLY TO A NOTICE OF VIOLATION

NRC INSPECTION

CONDUCTED

AUGUST 24. 1997 THROUGH OCTOBER 4.1997 SURRY POWER STATION UNITS 1 AND 2 INSPECTION

REPORT NOS. 50-280/97-09

AND 50-281/97-09

Violation

A 1. Reason for the Violation, or, if Contested, the Basis for Disputing

the Violation

2. The violation

is correct as stated. The vital bus* isolation

issue was identified

in 1992, and a station deviation

was issued. Following

identification

of this issue, a modification

was planned to restore vital bus isolation

in the event of a Main Control Room (MCR) fire. It was then considered

that the MCR being continuously

manned was an acceptable

compensatory

measure until the modification

was implemented.

A foundational

error occurred in 1992 in that these compensatory

measures were believed to be equivalent

to compliance

with the Appendix R design basis. Inappropriate

prioritization

of the required modification

resulted from this error. Contributing

causal factors were written and verbal communication.

Specifically, the documentation

regarding

the vital bus isolation

issue used ambiguous

language, which contributed

to the foundational

error. In addition, the significance

of the vital bus isolation

issue was not effectively

communicated

verbally, which also contributed

to the foundational

error. Corrective

Steps Which Have Been Taken and the Results Achieved As discussed

during the predecisional

enforcement

conference

on the December 4, 1997, a number of corrective

actions have been completed.

The completed

corrective

actions, which are summarized

in the following

paragraphs, focused on restoring

vital bus isolation

and ensuring that a situation

similar to the isolation

issue does not exist: -The design change implementing

the modification

to restore vital bus isolation

in the event of a MCR fire was completed

on Unit 2 during the October 1997 refueling

outage. With this design change completed

on Unit 2, the current capabilities

relative to vital bus isolation

are that: hot shutdown can be achieved and maintained

on both units with no repairs or compensatory

measures, cold shutdown can be achieved on Unit 1 without compensatory

measures, and cold shutdown can be achieved on Unit 2 using the compensatory

measures currently

in place. These compensatory

measures will remain in Page 3

• place until the modification

is completed

on Unit 1 during the next refueling

outage, scheduled

to begin in October 1998. -A Category 1 RCE was conducted

to determine

the root cause and contributing

causal factors in the untimely corrective

action associated

with the vital bus isolation

issue. The conclusions

from the RCE are incorporated

in the above discussion

of Reason for the Violation.

A number of corrective

actions related to the RCE have been approved for implementation, some of which are listed below in Item 3. -The fire protection

administrative

procedure

has been revised to address the implementation

of non-standard

compensatory

measures.

Non-standard

compensatory

measures are those actions that had not previously

been defined in the fire protection

administrative

procedure.

In contrast, standard compensatory

measures for anticipated

conditions, such as the action required when a fire barrier is found to be breached, are those that have been previously

defined and approved in the administrative

procedure.

Based on the recent administrative

procedure

revision, implementation

of a non-standard

compensatory

measure now requires an engineering

technical

evaluation, which considers

defense in depth, design basis, and safety significance

in defining the required actions. Briefings

were conducted

with on-shift Shift Technical

Advisors to familiarize

them with the revision to the administrative

procedure.

-An assessment

of the existing non-standard

compensatory

measures currently

in place was conducted.

This review identified

no issues or concerns.

-The Operating

Experience

group completed

a review of Information

Notice 97-48, titled Inadequate

or Inappropriate

Interim Fire Protection

Compensatory

Measures.

That review identified

the lack of guidance for implementation

of non-standard

compensatory

measures.

The administrative

procedure

revision discussed

above addresses

this observation.

Our December 4, 1997 presentation

included identification

of approximately

thirty design changes and engineering

work requests that were completed

primarily

in the 1984 to 1987 time to address the initial Appendix R requirements.

These design changes have been reviewed to verify that the Appendix R features installed

by these changes remain intact. * Page 4

-* * Independent

of the Appendix R issues, the corrective

action program was recently revised to reflect an enhanced process to prioritize

deviation

reports. A multi-disciplined, multi-departmental

team reviews the deviation

report assignments

and significance

levels proposed by the initial screening.

This team has been trained to recognize

issues of safety and regulatory

significance.

3. Corrective

Steps Which Will be Taken to Avoid Further Violations

The December 4, 1997 predecisional

enforcement

conference

included discussion

of a number of corrective

actions that are planned. The planned corrective

actions, which are summarized

in the following

paragraphs, focus on heightened

awareness

relative to Appendix R and effective

communication, as well as continued

programmatic

review of the Appendix R program: -Appendix R awareness

training will be conducted

for appropriate

personnel

in the Nuclear Business Unit. This training will focus on the Appendix R design and licensing

bases, as well as Appendix R compliance

and implications.

The awareness

training will include a discussion

of how insufficient

communication

contributed

to the inappropriate

prioritization

and delay in implementation

of the modification.

It is expected that this training will occur during the first quarter of 1998. -A memorandum

will be issued to appropriate

Nuclear Business Unit personnel

by February 1998 describing

how the use of ambiguous

language contributed

to the delay in implementation

of the required modifications

and reinforcing

the need for and management

expectation

of effective

communication.

A multi-utility

assessment

of our Appendix R Program will be conducted

using the applicable

portions of the draft Fire Protection

Functional

Inspection (FPFI) Temporary

Instruction

2515/xxx, which was used during the recent River Bend FPFI. This assessment

had been scheduled

for January 1998. We recently advised the NRC that this assessment

has been postponed

until April 1998. [Reference:

Letter S/N 98-020] -A multi-disciplined

review of portions of the Appendix R Report will be conducted.

This review will include Chapters 3, "Safe Shutdown Systems Analysis," and 4, "Appendix

R Section 111.G Compliance

Summary." For the chapters being reviewed, the accuracy of the Appendix R Report will be assessed relative to the current plant configuration, and compliance

with the Appendix R requirements

will be confirmed.

This review is scheduled

for completion

by July 15, 1998. Related to Information

Notice 97-48, titled Inadequate

or Inappropriate

Interim Fire Protection

Compensatory

Measures, a review of the fire protection

administrative

procedure

noted that the standard compensatory

measures as they currently

exist (in the administrative

procedure)

vary depending

on the equipment

that is inoperable.

The administrative

procedure

will be expanded to include the original bases for the existing compensatory

measures.

Page 5

Consistent

with the guidance in Information

Notice 97-48, the fire-watch-only

compensatory

measures will be reviewed for possible expansion

to include other interim measures, such as operator briefings, temporary

repairs or procedures, installation

and use of temporary

fire barriers, and additional

detection

and suppression, as appropriate.

This additional

review and revision is scheduled

for completion

by July 1, 1998. 4. The Date When Full Compliance

Will be Achieved . In view of the current capabilities

relative to vital bus isolation, which are outlined in Item 2 above, compliance

with Appendix R requirements, as well as with the Surry Appendix R design basis requirements, was achieved when the modification

was completed

on Unit 2 during the last refueling

outage ending in November 1997. Upon completion

of the Unit 1 modification

during the refueling

outage scheduled

to begin in October 1998, compliance

with the Surry Appendix R . licensing

basis will also be achieved.

Violation

B 1. Reason for the Violation, or, if Contested, the Basis for Disputing

the Violation

The violation

is correct as stated. As noted in the response to Violation

A, a foundational

error occurred in 1992 in that these compensatory

measures were believed to be equivalent

to compliance

with the Appendix R design basis. Inappropriate

prioritization

of the required modification

resulted from this error. Therefore, implementation

of the modification

required to restore vital bus isolation

was delayed. The delay in correcting

the vital bus isolation

issue is attributed

to the fact that the postponement

was not sufficiently

challenged

in view of the foundational

error that compensatory

measures suffice for compliance.*

2. Corrective

Steps Which Have Been Taken and the Results Achieved As noted in the response to Violation

A, a number of corrective

actions have been taken related to the vital bus isolation

issue. The actions directly associated

with the delay in accomplishing

the modification

to restore vital bus isolation

are the following:

-The recent Category 1 RCE was conducted

to determine

the root cause and contributing

causal factors in the untimely corrective

action associated

with the vital bus isolation

issue. The conclusions

from the RCE are reflected

in the above discussion

of Reason for the Violation.

A number of corrective

actions related to the RCE have been approved for implementation, some of which are listed below in Item 3. Page 6

• * * 3. 4. Independent

of the Appendix R issues, the corrective

action program was recently revised to reflect an enhanced process to prioritize

deviation

reports. A multi-disciplined, multi-departmental

team reviews the deviation

report assignments

and significance

levels proposed by the initial screening.

This team has been trained on significance

levels. Corrective

Steps Which Will be Taken to Avoid Further Violations

As noted in the response to Violation

A, a number of corrective

actions are planned related to the vital bus isolation

issue. The actions directly associated

with heightened

sensitivity

related to the timeliness

of Appendix R corrective

_ actions are the following:

-Appendix R awareness

training will be conducted

for appropriate

personnel

in the Nuclear Business Unit. This training will focus on the Appendix R design and licensing

bases, as well as Appendix R compliance

and implications.

The awareness

training will include a discussion

of how insufficient

communication

contributed

to the inappropriate

prioritization

and delay in implementation

of the modification.

It is expected that this training will occur during the first quarter of 1998. -A memorandum

will be issued to appropriate

Nuclear Business Unit personnel

by February 1998 describing

how the use of ambiguous

language contributed

to the delay in implementation

of the required modifications

and reinforcing

the need for and management

expectation

of effective

communication.

The Date When Full Compliance

Will be Achieved In view of the current capabilities

relative to vital bus isolation, which are outlined in Item 2 of the response to Violation

A, compliance

with Appendix R requirements, as well as with the Surry Appendix R design basis requirements, was achieved when the modification

was completed

on Unit 2 during the last refueling

outage ending in November 1997. Upon completion

of the Unit 1 modification

during the refueling

outage scheduled

to begin in October 1998, compliance

with the Surry Appendix R licensing

basis will also be achieved.

Violation

C 1. Reason for the Violation, or, if Contested, the Basis for Disputing

the Violation

The violation

is correct as stated. On September

30, 1997, when it was determined

that Surry had been outside the Appendix R design basis due to the vital bus isolation

issue, adequate compensatory

measures were in place. With those compensatory

measures in place, the required Appendix R function of achieving

and maintaining

safe shutdown conditions

could have been ac,complished

in the event of a MCR fire. Page 7

• * Additionally, with the compensatory

measures in place, it was believed we were in compliance

with the Appendix R design basis. Therefore, a one-hour report was not made to the NRC. Instead, a Licensee Event Report was issued on October 30, 1997. Based on the NRC input provided in Inspection

Report 97-09, we recognize

that 1 OCFR50, Appendix R, Section 111.G.1.(a)

requires that hot shutdown conditions

be achieved and maintained

without repairs, in contrast to Section 111.G.1.{b)

which allows repairs to achieve and maintain cold shutdown conditions.

At that time, the compensatory

measures in place required the disconnection

of a UPS cable and the possible replacement

of fuses (i.e., repairs) to achieve and maintain hot shutdown conditions

on both units. Therefore, in this case, a one-hour report should have been made when it was determined

that Surry had been outside the Appendix R design basis due to the vital bus isolation

issue and prior to the modification

being completed

on Unit 2 during the last refueling

outage ending in November 1997. 2. Corrective

Steps Which Have Been Taken and the Results Achieved We have reviewed the NRC's comments regarding

reportability

in Inspection

Report 97-09 in view of Surry's current configuration.

As noted in the response to Violation

A, with the design change completed

on Unit 2, the current capabilities

relative to vital bus isolation

are that: hot shutdown can be achieved and maintained

on both units with no repairs or compensatory

measures, cold shutdown can be achieved on Unit 1 with no compensatory

measures, and cold shutdown can be achieved on Unit 2 using the compensatory

measures currently

in place. Therefore, relative to vital bus isolation, compliance

with the Appendix R requirements, as well as with the Surry Appendix R design basis requirements, was achieved when the modification

was completed

on Unit 2. So a one-hour report was no longer necessary

as of the completion

of the Unit 2 refueling

outage in November 1997. 3. Corrective

Steps Which Will be Taken to Avoid Further Violations

As noted in the response to Violation

A, a number of corrective

actions are planned related to the vital bus isolation

issue. The action directly associated

with the reportability

aspects of the vital bus isolation

issue is the following:

Appendix R awareness

training will be conducted

for appropriate

personnel

in the Nuclear Business Unit. This training will focus on the Appendix R design and licensing

bases, as well as Appendix R compliance

and implications.

It is expected that this training will occur during the first quarter of 1998. Page 8

4. The Date When Full Compliance

Will be Achieved In view of the current capabilities

relative to vital bus isolation, which are outlined in Item 2 of the response to Violation

A, compliance

with Appendix R requirements, as well as with the Surry Appendix R design basis requirements, was achieved when the modification

was completed

on Unit 2 during the last refueling

outage ending in November 1997. Upon completion

of the Unit 1 modification

during the refueling

outage scheduled

to begin in October 1998, compliance

with the Surry Appendix R licensing

basis will also be achieved.

Page 9

' REPLY TO A NOTICE OF DEVIATION . NRC.INSPECTION

CONDUCTED

AUGUST 24, 1997 THROUGH OCTOBER 4, 1997 SURRY POWER STATION UNITS 1 AND 2 INSPECTION

REPORT NOS. 50-280/97-09

AND 50-281/97-09

NRG COMMENT: "During an NRG inspection

conducted

on August 24 through October 4, 1997, a deviation

of your Updated Final Safety Analysis Report (UFSAR) was identified.

In accordance

with the "General Statement

of Policy and Procedures

for NRG Enforcement

Actions," NUREG-1600, the deviation

is listed below: UFSAR Section 9.10.1 states that the station's

fire protection

program satisfies

the regulatory

criteria set forth in General Design Criterion 3, in 10 CFR 50 Appendix R (Sections

111.G, 111.J, 111.L and 111.0), and in Appendix A to Branch Technical

Position APCSB 9.5-1 dated August 23, 1976. Compliance

with these criteria is contained

in the 10 CFR 50 Appendix R Report, Surry Power Station Units 1 and 2. The 10 CFR 50 Appendix R Report, Surry Power Station, Units 1 and 2, Revision 11, Chapter 9, Electrical

Distribution

System Coordination

Study, Section 9.1, states that coordination

of circuit protective

devices to prevent unnecessary

outages of power supplies needed for safe shutdown is required to conform to the requirements

of Appendix R. The Appendix R Report states that components

involved in critical circuits were investigated

and data gathered to facilitate

verification

of the capability

of the interrupting

devices to operate selectively

and to continue to supply power to all critical circuits not affected by the postulated

fire. Section 9.2 of Chapter 9 concluded

that miscoordination

existed on the 120 volt alternating

current (VAC) bus system due to the maximum half cycle instantaneous

current supplied by the bypass transformers.

The Appendix R report states that, to assure coordination, the Square D 100 ampere (amp) trip main circuit breakers in each vital bus panel will be replaced with non-automatic

molded case switches.

Contrary to the above, the 100 amp breakers were not replaced with non-automatic

switches as committed

to in the Appendix R Report to ensure compliance

with UFSAR Section 9.10.1. This resulted in inadequate

breaker coordination

between the vital bus branch circuits and vital bus main panel breaker of the vital bus panels supplying

circuits installed

in the Units 1 and 2 emergency

switchgear

rooms and the Turbine Building.

Each of these panels supply Appendix R and safe shutdown related components." Page 10

I * REPLY TO A NOTICE OF DEVIATION

NRC INSPECTION

CONDUCTED

AUGUST 24. 1997 THROUGH OCTOBER 4. 1997 SURRY POWER STATION UNITS 1 AND 2 INSPECTION

REPORT NOS. 50-280/97-09

AND 50-281/97-09

1. Reason for the Deviation, or, if Contested, the Basis for Disputing

the Deviation

The deviation

is correct as stated. Although breaker coordination

is not required to comply with the Appendix R design base, it is assumed in the Appendix R Report and therefore

is a commitment

consistent

with the Appendix R licensing

basis for Surry. The breaker coordination

issue was identified

in 1993, and a station deviation

was , issued. When this issue was identified, it was recognized

that a postulated

high fault current and the resultant

potential

breaker miscoordination

was a highly unlikely event. In addition, the potential

loss of a single vital bus was a condition

addressed

by procedure.

The modification

required to address breaker coordination

was coupled with the modification

planned to address the vital bus isolation

issue and included in a single design change package. As stated in the responses

to Violations

A and B, the modification

required to restore vital bus isolation

was inappropriately

prioritized

and the implementation

was delayed. Therefore, it followed that the modification

required to address breaker coordination

was also inappropriately

prioritized

and its implementation

was also delayed. 2. Corrective

Steps Which Have Been Taken and the Results Achieved The design change implementing

the modification

to address the breaker coordination

issue was completed

on Unit 2 during the October 1997 refueling

outage. 3. Corrective

Steps Which Will be Taken to Avoid Further Violations

4. The design change is scheduled

to be completed

on Unit 1 during the next refueling

outage, scheduled

to begin in October 1998. The compensatory

measures currently

in place will remain in place until the modification

is completed

on Unit 1. The Date When Full Compliance

Will be Achieved Full compliance

will be achieved regarding

the breaker coordination

issue when the required modification

is implemented

on Unit 1 during the next refueling

outage scheduled

to begin in October 1998. Page 11